122 T.C. No. 15 UNITED STATES TAX COURT ROBERT EUGENE POINDEXTER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14428-01L. Filed March 29, 2004. P reported tax on his 1994 and 1996 Federal income tax returns but did not remit those amounts. R assessed those amounts and demanded payment thereof. After several years of continued nonpayment, R issued to P a notice of intent to levy. P timely requested a hearing pursuant to sec. 6330, I.R.C. At the hearing, P asserted that the amounts of tax shown on his 1994 and 1996 returns are incorrect but would not say whether he believed his correct income to be higher or lower than the amounts reported. R subsequently issued to P a notice of determination upholding the proposed collection action. P timely petitioned the Court for review, and R moved for summary judgment. 1. Held: A taxpayer who reports an amount of tax on his tax return is not precluded from challenging the accuracy of that amount at a sec. 6330, I.R.C., hearing. Montgomery v. Commissioner, 122 T.C. 1 (2004), followed.Page: 1 2 3 4 5 6 7 8 9 10 11 Next
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